1315 Effort Reporting: Certifying Effort on Sponsored Projects

Policy Sections

1315.1 Proposing Effort and Requesting Salary Support

1315.2 Proposing Graduate Student Stipends and Tuition Remission

1315.3 Establishment of Salaries on Sponsored Project Accounts

1315.4 Completion and Certification of Effort Certification Statements (ECSs)

1315.5 Summer Effort/Salary for Faculty with 9-Month Academic Appointments

1315.6 Salary Reallocations & Recertification

1315.7 Sanctions for Non-Compliance

This document sets forth the University’s policy on certification of effort expended on sponsored project awards administered by the University.  This Policy applies to all individuals who commit and devote effort to a sponsored project as well as those individuals involved in certifying the effort of individuals on a sponsored project.

• The University is committed to ensuring that effort statements completed in connection with sponsored projects are accurate.
• All faculty and staff who are involved in allocating salaries and wages to sponsored projects, managing sponsored projects, or completing Effort Certification Statements (ECS) are responsible for understanding the principles of accurate and timely effort reporting.
• In no case can the percentage of an individual’s salary charged to a sponsored project exceed the percentage of the individual’s total effort that is expended on the project during an effort reporting period.
• If the percentage of total effort expended in a given effort reporting period is less than the percentage of salary charged to the sponsored project during the period, the salary charges must be reduced to reflect actual effort.

To ensure that effort certifications completed in connection with University sponsored projects are accurate, reasonably reflect the actual level of effort expended on a sponsored project, and comply with sponsor requirements.

As a condition of receiving sponsored awards, the University must assure sponsors that the effort expended on their sponsored projects justifies the salary charged to those projects.  In addition, the University must assure sponsors that the commitment indicated (including mandatory and voluntary committed cost sharing) in the proposal and subsequent award is met in accordance with the sponsor’s terms and conditions.  The University provides this assurance by requiring periodic effort statements (Effort Certification Statements) for each individual whose salary is charged to one or more sponsored projects and/or cost sharing accounts during the effort reporting period or for an individual whose compensation is supported by an external Yale source (for example, the Howard Hughes Medical Institute) and is devoting effort committed to a sponsored project.  Completed effort statements indicate the percentages of the individual’s total effort that are dedicated to the sponsored project(s) and other University activities and require a certification that the reported effort percentages are reasonable and accurate.

Each faculty member must be aware of his/her level of committed effort to sponsored projects, their ability to meet those commitments in light of any other University obligations they may have and to communicate any significant changes in level of sponsored projects effort to his/her respective business office.  Please refer to Policy 1316 Effort Commitment: Managing Effort Associated with Sponsored Projects.

Financial penalties, expenditure disallowances, and harm to the University’s reputation could result from failure to provide accurate effort certifications or failure to comply with the University’s effort reporting requirements.  All individuals involved in the effort certification process are expected to abide strictly by the provisions of this policy.

Effort

Effort is the time spent on any activity by an individual, expressed as a percentage of the individual’s total University effort.

Total University Effort

Total University effort (sometimes referred to as “total effort”) is the professional activity for which an individual is compensated by Yale.  Although the scope of total University effort may differ somewhat among faculty, the following table illustrates the kinds of activities that would typically be considered part of the total University effort of a faculty member.  Refer to Policy 1316 Effort Commitment: Managing Effort Associated with Sponsored Projects for a discussion on how an employee’s Institutional Base Salary provides compensation for [Total University Effort].

Effort Reporting

Effort reporting is the process by which the University determines and documents the effort expended on sponsored projects during each effort reporting period.  The Effort Certification Statement (ECS) documents the proportion of time devoted to sponsored projects, teaching, clinical practice, and other activities, expressed as a percentage of total University effort.  The denominator of the effort percentage must always be total University effort, irrespective of the total number of hours worked during the effort reporting period.  For example, if a faculty member works an average of 50 hours per week during an effort reporting period and works an average of 10 hours per week on a particular sponsored project, the correct effort percentage for that project would be 20%.

Payroll Costing

Payroll costing is the process of assigning salary charges to sponsored projects and other University activities.  Payroll costing and effort allocations are not the same thing.  If payroll costing to a sponsored project during an effort reporting period exceeds the percentage of effort expended on the project during the period, payroll costing must be reduced to the level of the effort actually expended, based on the effort report.

Effort Certification

Effort certification is the affirmation by the individual completing each Effort Certification Statement (ECS) that the percentages of effort reported on the statement are accurate.  Knowingly signing an inaccurate effort certification is a serious violation of University policy, as well as potentially a violation of civil and criminal fraud statutes.

Levels of effort proposed in any sponsored project application should be consistent with the actual effort that each individual is expected to expend on the project during the relevant project period(s).  The amount of salary support requested should normally be determined by multiplying the proposed level of effort by the individual’s Institutional Base Salary.  Sponsor supported salary for proposed effort is normally requested in the budget and/or budget justification of the proposal, unless the type of submission/award would preclude such a request.

For proposal purposes, proposed level of effort must be expressed in accordance with sponsor requirements.  Some sponsors require that level of effort be proposed in terms of person months (e.g., three person months of a 12-month appointment).  Other sponsors expect the proposed level of effort to be expressed in percentage terms (e.g., 25% of total effort).  In either case, the requested salary support should normally be determined by multiplying the proposed level of effort by the individual’s Institutional Base Salary.  For example, if the proposed level of effort is 25% (or three months in a 12-month appointment), and the individual’s Institutional Base Salary is $100,000, normally the requested salary support would be $25,000 per year.

In some cases, the amount of requested salary support may be less than this amount (see below).  In no event should the requested salary support exceed the amount determined by multiplying the proposed level of effort by Institutional Base Salary.

In general, an individual’s Institutional Base Salary (IBS) includes all amounts paid to the individual by the University as compensation for services rendered.  There are certain elements of compensation, however, that are excluded from IBS.  Refer to Policy 1311 Institutional Base Salary for Sponsored Projects.

Some sponsors, most notably NIH, impose limitations on the amount of IBS that may be used as a basis for charging salary to their projects.  Where such limitations apply, the requested salary support is determined by multiplying the proposed level of effort by the maximum IBS allowed (e.g., the NIH salary cap).  Refer to Policy 1311 Institutional Base Salary for Sponsored Projects and Procedure 1315 PR.03 Salaries Above a Sponsor Imposed Rate Cap and Other Program Salary Limitations.

In certain circumstances, the University may elect to request salary support that is less than the salary support that could be requested based on proposed level of effort.  Refer to Policy 1306 Cost Sharing on Sponsored Projects.  Nevertheless, the total amount of effort committed to the project must be provided or, if necessary, sponsor approval must be obtained to reduce the commitment.  In all cases, employees must certify their effort report accurately.

Sponsors generally consider estimates of effort (and corresponding salary requests) in project proposals to be commitments if such proposals are subsequently awarded.  Refer to Policy 1316 Effort Commitment: Managing Effort Associated with Sponsored Projects.  Principal Investigators and other key personnel for whom such commitments have been made are responsible for ensuring that the commitments are met and, if necessary, sponsor approval is obtained to reduce the commitment.  The effort levels reported in effort statements can be a source of information on that subject, but ultimately the responsibility for meeting the commitments lies with the individual.

If a proposal requests support for a graduate student in the form of a stipend the proportionate amount of tuition remission should also be requested from the sponsor.  Depending on the percentage of the total stipend charged to a sponsored award, that same percentage is applied to 50% of the amount of tuition (the University supports the remaining 50% which is considered a form of cost sharing) and included in the budget to the sponsor.  For example, a PI budgets for a FTE graduate student at a stipend of $17,000 per year.  The tuition remission in the budget would be at a rate of 50% of $34,500 (total cost of the tuition for the year) or $17,250.

Salary distribution consistent with the projected effort should begin on sponsored projects accounts concurrently with actual project effort.  It is each faculty member’s responsibility to be aware of his/her level of effort and to communicate any significant changes in level of effort to his/her respective business office to ensure that salary distributions are reviewed and updated, if appropriate, on a timely basis.  Refer to Policy 1316 Effort Commitment: Managing Effort Associated with Sponsored Projects.

On a regular basis (every six months and separately for 9-month faculty with summer compensation) an Effort Certification Statement (ECS) will be generated in Workday for faculty, managerial and professional, clerical and technical staff, and post-doctoral associates whose compensation was charged in whole or in part to a sponsored project during the respective effort period.  These ECSs must be completed, certified, and submitted in accordance with this policy.

Similarly, for graduate students, ECSs will be generated based on spring and fall academic term with an additional summer reporting period in Workday.  When certifying graduate student effort represented in the form of a Stipend charged to an award, the PI/responsible individual is also certifying that tuition remission is proportional to the student’s level of effort and Stipend directly charged to the award.  These ECSs must also be completed, certified, and submitted in accordance with this policy.

The ECS will contain data indicating the percentages of the individual’s University salary that were allocated to sponsored project accounts and other University activities.  These salary allocation percentages are not effort percentages; they are provided solely for informational purposes.

However, in certain situations, individuals not receiving salary from Yale, (for example, Howard Hughes Medical Institute Investigators), or who receive salary from a sabbatical or leave of absence account, or paid from Executive (Confidential) Payroll and devoting committed effort to a sponsored project, will not receive an ECS generated in Workday to support the effort devoted to the sponsored project.  In such cases, the completion of Form 1315 FR.01 Effort Report, in accordance with the University’s policies, is required.

When completing an ECS, certifiers are expected to review the summary of payroll costing percentages on the effort statement, and determine whether those percentages reasonably correspond to the percentages of the individual’s actual effort on each project or activity recognizing that within an academic setting, teaching, research, service, and administration are often inextricably intermingled.  If salary percentages reflect the actual effort, the person completing the form (certifier) should certify the effort report form in accordance with University procedures.

(See Procedure 1315 PR.04 Effort Reporting for additional instructions in completing an effort report form.)

When certifying the ECS, the criterion to be used is how the individual’s effort was expended for the reporting period.  Factors such as the availability of funds or the level of committed effort should not influence the certification.

The completed effort statement must reflect all activities for which compensation is paid by Yale University.  The total work effort expended cannot be more or less than 100%.

Most faculty members are engaged in teaching, administrative and other duties in addition to their work on sponsored projects.  Accordingly, unless the circumstances of a particular faculty member demonstrably warrant otherwise, the total effort and salary of a faculty member should normally not be assigned to sponsored projects in a given effort period.

If for any reason the person completing the statement has questions or concerns about how the statement should be completed or certified, s/he should consult the appropriate business administrator of their department, the Effort Certification Manager, and the University Research Compliance Officer, if necessary.

Who can certify Effort Statements?

Faculty members are required to certify their own effort statements.

The Grant Principal Investigator certifies the effort statements of the research staff working on his or her sponsored projects.  If the PI does not have a suitable means of verifying the effort of the research staff, s/he should not certify the effort statements and should contact the Office of Research Compliance Effort Certification Manager to discuss how those effort statements should be completed.

In accordance with the Procedure on Effort Reporting, faculty and other employees are responsible for completing effort certifications within 60 calendar days from the time that ECSs are available for certification.

In the event of extraordinary circumstances where a faculty member is unavailable to certify his/her effort statement or has left the University, the Office of Sponsored Projects’ Effort Certification Manager should be notified and will determine the appropriate steps to take to achieve meaningful certification.

Faculty compensated for 9-month academic appointments are permitted to expend up to an additional 2.5 months of summer effort on one or more sponsored projects in the period beyond the academic year (i.e., during the summer research period) and earn up to 2.5 months of additional salary for that effort, subject to sponsor policies and the approval of the department chair and dean/provost.

If a faculty member has administrative or other non-research responsibilities during the summer period, they may be precluded from devoting 100% effort to sponsored projects and thus from requesting 2.5 months of salary from those sponsored projects.  Refer to Policy 1316 Effort Commitment: Managing Effort Associated with Sponsored Projects.

The provisions of this policy relating to the reporting and certification of effort apply fully to the reporting and certification of summer effort.  Specifically, charging summer salary to one or more sponsored projects implies that at least a commensurate amount of effort has been expended on those projects during the summer effort period.  Faculty who receive summer salary from sponsored projects must certify to the effort expended on those projects during the summer effort period.  Effort expended during the academic year cannot be counted for this purpose.

Summer effort of faculty with a nine-month appointment must be supported by the equivalent salary charged to the sponsored award to which the effort was devoted.

Salary reallocations made as a result of the effort certification process must be made in accordance with University policies and procedures on salary reallocations and cost transfers.

Once certification of effort has been completed, only in certain rare circumstances will subsequent salary adjustments be permitted.  Refer to Procedure 1305 PR.02 Cost Transfers Involving Sponsored Projects.

Failure to follow the provisions of this effort reporting policy may subject the individuals and departments responsible for the violation(s) to administrative and/or disciplinary actions in accordance with University disciplinary procedures and the judgment of management.  Specifically, and without limitation,

1.  If ECSs are not completed and returned in a timely manner, salary costs associated with uncertified grant activity may be removed and charged to a departmental account.

2.  OSP may suspend submission of any new proposals on behalf of a noncompliant PI, or inclusion of a noncompliant researcher in proposals, until effort reports are up to date and properly completed and certified.

3.  Certification of effort statements that are known to be materially inaccurate may expose the individual who completed the reports to personal disciplinary action.

Principal Investigator/Faculty

• Responsible for understanding the principles of accurate effort reporting.
• Must be aware of the level of effort committed to a sponsor in relation to all other professional activities included in total effort
• When appropriate, request sponsor approval for reductions in effort greater than 25%.
• Identify situations where the salary representing the effort devoted to an award is more than the actual percent of effort devoted to the award.
• Request a change of effort on the ECS when inaccuracies exist.
• Must certify his/her own statement and should certify ECS of others working on his/her awards.
• In accordance with Procedure 1315 PR.04 Effort Reporting, complete the effort report within 60 days from the date of availability.
• 9-month faculty receiving summer salary during the summer months must ensure that the effort was expended during the summer effort reporting period for which they were funded.
• Review, approve, and sign manual effort form templates if for example, terminating employment with the University and the effort reports are not yet generated through ERS

Effort Certification Reviewers

• Encouraged to complete Administrative Review of effort statements within the first fifteen days of availability.
• Review effort statements for accuracy prior to releasing to the certifier.
• Ensure that sponsor-imposed salary caps are calculated and appropriate salaries are recorded properly.
• Provide certifiers with a better understanding of effort reports and the effort reporting process.
• Make any necessary adjustments requested by the certifier to the ECS.
• Ensure that effort statements are completed and certified and in accordance with Procedure 1315 PR.04 Effort Reporting.
• Retain supporting documentation related to salary and effort distributions.
• Complete a manual effort form template(s) prior to the departure of a certifier from the University for those individuals for which the certifier is responsible to certify (including him/herself).  Templates would be necessary if ECSs are not yet available for the reporting period.

Office of Sponsored Projects

• Review and approve University requests for reductions of effort as required by sponsor terms and conditions.
• Notify the community regarding the availability of effort statements for certification.
• Monitor the effort certification process.
• Assist with questions regarding effort reporting principles and/or process.
• Review ECSs for compliance with University policy.